Privacy Data

THIS STATEMENT PROVIDES GENERAL INFORMATION ABOUT THE PRIVACY STATEMENT OF THIS WEBSITE AND ITS RELATED APPS (MOBILE OR OTHERWISE). IF YOU ARE UNDER 13 YEARS OF AGE, PLEASE BE SURE TO READ THIS PRIVACY STATEMENT WITH YOUR PARENTS OR GUARDIAN AND ASK THEM QUESTIONS ABOUT WHAT YOU DO NOT UNDERSTAND.

YOUR USE OF THIS SERVICE CONSTITUTES ACCEPTANCE BY YOU OF THIS PRIVACY STATEMENT.

GameGleam has created this privacy statement (“Statement”) in order to demonstrate its firm commitment to the privacy of the details that you provide to us when using www.gamegleam.com , as the data controller for the purposes of the GDPR (General Data Protection Regulations EU 2016/679) and related UK legislation.

At GameGleam, we are committed to maintaining the trust and confidence of all visitors to our web site. In particular, we want you to know that GameGleam is not in the business of selling, renting or trading email lists with other companies and businesses for marketing purposes.

We believe your business is no one else’s. Your Privacy is important to you and to us. So we’ll protect the information you share with us. To protect your privacy, GameGleam follows different principles in accordance with worldwide practices for customer privacy and data protection.

- We won’t sell or give away your name, mail address, phone number, email address or any other information to anyone.

- We‘ll use state – of – the – art security measures to protect your information from unauthorized users.

Therefore, to provide you with our services we need (and sometimes are obliged by the law) to collect your personal data. This Privacy Policy (the “Policy”) informs Users (a "User", "You") of our policies regarding the processing of Personal Information we receive from Users of www.gamegleam.com .

In this Privacy Policy, we’ve provided detailed information on when and why we collect personal information, how we use it, the limited conditions under which we may disclose it to others, and how we keep it secure.

We take your privacy seriously and take measures to provide all visitors and users of www.gamegleam.com with a safe and secure environment.

This website, our related websites and any mobile site or mobile application that link to this privacy policy (collectively, the “site”, “sites”) are owned and operated by INFINITOUS GROUP with Company registration number: 970326-5034 and its principal place of business at Stockholm, Sweden

The Personal Information on the www.gamegleam.com , is collected, controlled and processed by the following entities:

INFINITIOUS GROUP

Stockholm, Sweden

E-mail: business@gamegleam.com

1. THIS POLICY

This Policy explains our processing of your personal data and your rights according to EU General Data Protection Regulation and UK data protection legislation. GameGleam reserves the right to modify this Statement at any time without notice by posting the changes on this webpage.

2. DEFINITIONS

“Personal Data” means any information which relates to a living, identifiable person. It can include names, addresses, telephone numbers, email addresses etc but it is wider than that and includes any other information relating to that person or a combination of information which, if put together, means that the person can be identified.

“Special Category data” means personal data about a person’s race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health, sex life or sexual orientation.

“Processing” covers all activities relating to the use of personal date by an organization, from its collection through to its storage and disposal and everything in between.

“Data subject” means the person whose personal data is being processed.

“Consent” any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

"Controller” the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

"Data handling” any set of operations or operations performed in an automated or not automated manner on personal data or files, thus collection, capture, systematization, distribution, storage, transformation or alteration, query, introspection, use, communication, forwarding, distribution or by any other means of making data available, coordination or interconnection, restriction, deletion or destruction;

"Data controller” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

"Addressee” means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not;

"Third party” means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;

"Profiling” any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements and;

"Privacy data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

3. RULES OF DATA HANDLING

The Data Controller recognizes the contents of this Data Management Guide as binding on itself, and states, that all data management related to his/her own activity is consistent and complies with the legal provisions as stated in the normative European Union and domestic data protection laws and with the applicable domestic sectoral laws, so especially:

- on the protection of natural persons with regard to the processing of personal data and on the free movement of such data as well as about the Regulation No. 2016/679 adopted by the European Parliament and the Council on 27 April 2016 about the repeal of 95/46/EK directive (hereinafter referred to as “GDPR” or “Regulation”)

- act CXII of 2011 on the Right to Self-Determination of Information and Freedom of Information;

- Act C of 2000 on Accounting;

- Act CL of 2017 on the Order of Taxation;

- Act V of 2013 on the Civil Code.

Act XLVIII of 2008 on the Essential Conditions and Certain Limitations of Economic Advertising Activities (hereinafter referred to as "Grt.").

The Data Controller defines his / her data management in such a way that it with the principles set out in the GDPR - legality, fairness and transparency, purpose limitation, data saving and accuracy, limited storage, integrity and confidentiality, as well as accountability – complies fully.

Accordingly, the Data Controller handles the collected, stored (managed) personal data solely for the clear and legitimate purposes defined and described below in subsequent paragraphs and only for the time stated. Thus, the subjects can read in detail about each of the data management activities in the mentioned points.

The legal basis for data management of the Data Controller is typically the consent of the data subject, the fullfillment of the contract concluded with the data subject, its preparation and the fulfillment of the legal obligation.

The consent-based data management will only take place if the data subject has given a clear, concrete, informed and unambiguous consent to the processing of personal data concerning the natural person by a clear affirmative action, such as a written declaration, including doing it in an electronic way. The consent of the data subject can be specified by ticking the checkbox on the Website. Giving consent also means that the data subject has read and understood this Privacy Policy and contributes to the Data Controller's data management based on the information provided herein. The data subject is entitled to withdraw his consent at any time. Withdrawal of consent does not affect the legality of the consent-based data management prior to revocation.

The legal basis for data management will be the fullfillment of the contract if the data subject uses the service from the Company, for example through the Website, i.e. a contractual relationship between the concerned (user) and the Company.

We're talking about statutory data management when a law obliges Data Controller to include some data as well as the duration of data storage.

Data Controller ensures data security and proper management. The Data Controller ensures that the data is stored in a form that allows identification of data subjects only for the time necessary to achieve the purposes for which personal data are processed. He/she also takes the technical and organizational steps to ensure that the data processed is adequately protected. Within this framework, he/she will take reasonable measures to prevent unauthorized access, alteration of use, transmission, disclosure, deletion or destruction, as well as unavailability of accidental destruction and damage resulting from changes in the technique used.

Therefore the Data Controller's staff shall ensure that unauthorized persons do not access personal data and that the storage and placement of personal data is designed in such a way that it is not accessible, accessible, alterable, destroyed, or destroyed by an unauthorized person.

The Company undertakes that the personal data of the data subjects will only be forwarded to the addressee (third party or data processor) who also handles the personal data provided or transmitted to them in accordance with these principles. The Company does not sell the data of the affected persons.

The users of the Website are also responsible for the security of their data. For protecting Your username and password, please be careful about the security of these data and not give it to third parties.

4. INFORMATION WE COLLECT

As part of the process of using www.gamegleam.com and the Services, we require you to give us certain Personal Information which we need to provide our Service. Without this information we may not be able to fulfil our obligations with you. This information includes:

General;

While providing our services we may collect the “Personal Information” which is defined as any information that identifies or can be used to identify, contact, or locate the person to whom such information pertains. Namely, we may collect:

Identity information: name, facial image, social security number, ID number, documents proving your identity and any other information they may contain;

Residential information: IP address, residence address, documents proving your residency and any other information they may contain;

Contact information: email address, mailing address, phone number;

Security information: alias, passwords;

Financial and billing information: number of bank accounts and names of banking institutions, identifiers in payment systems or other means of payment, information on your balance accounts, your trade history, incoming and outgoing wallet addresses;

Cookies: to know more about cookies please acquaint yourself with Our Cookie Policy;

5. HOW WE USE INFORMATION

We, our authorized partners and our representatives store and use Your Personal Information only for providing and improving the website. In particular, we use Users' Personal Information for the following purposes:

To improve our services to you and to provide you with the Services requested: We run the following processes to fulfill our obligations with you:

- Enabling you to access the Site and create an account

- Enabling you to communicate with other users, and receive updates from GameGleam about your account

- Enabling payments

- Providing support to you when you use GameGleam

- Enable you earn points on the site.

- Enable you play games through partners

- Providing photos and videos to create trust and enable better connections between users

- To facilitate Socialization as users would be able to add people as friends, message them, create content in form of Articles, rating Articles, commenting and liking comments.

To comply with our legal obligations: In many jurisdictions we are obliged to collect certain information about our Users to be authorized to act;

a. It is necessary for the performance of a contract to which you are a party, or to take steps prior to entering into a contract with you, for us to provide you with our services. Where we require information from you for these purposes we have set out above which information it is necessary for us to process, without which we will be unable to provide you with our services.

b. It is necessary for the purposes of our legitimate interests, such as fraud prevention, child protection, maintaining quality of service, error detection and cyber security, except where our interests are overridden by the interests, rights or freedoms of affected individuals (such as you). To determine this, we shall consider a number of factors, such as what you were told at the time you provided your data, what your expectations are about the processing of the data, the nature of the data, and the impact of the processing on you. In order to protect children from harassment and abuse, we video record and store tutoring sessions.

c. Where we need to comply with a legal obligation; or in rare circumstances:

d. Where we need to protect your interests (or someone else's interests); and/or

e Where it is needed in the public interest or for official purposes

To improve customer service: information provided by Users helps us respond to customer service requests and support needs more efficiently;

To support our legitimate interests in developing the Site and the Services: These processes include:

- To aid the technical administration of the Site;

- To better understand how the Site is functioning for Users to inform our product development;

- To draw conclusions upon demographic information and;

- Preventing fraud, spam and abusive or inappropriate behavior and;

- Marketing activities to promote our services to registered users. These communications may be personalized to you and your interactions with the Site and can be delivered by email, social media advertising and other digital marketing channels

- Notifying you about upcoming promotions, Referral Discount Codes, services or customer surveys

- Undertaking impact reporting to understand the efficacy of our Services

- Undertaking research to better understand our customers interests

- Analysing your interactions to improve the efficiency of our marketing activity.

To personalize User experience: We may use information in a general manner to understand how Our Users as a group use the services and resources provided on our website;

To send periodic emails: We may use the email address to send information and updates pertaining to your use of the transaction request;

To resolve disputes and enforce our agreements to the extent necessary and sufficient for protecting your interests or interests of other Users.

To deliver our services: We may use your information to contact you about GameGleam updates, to provide informational & service-related communications, including important security updates.

Information you share in public areas of GameGleam or profile database may be accessed, used, and collected by others around the world. We try to provide a secure environment by endeavouring to limit access to our database to legitimate users, but we cannot ensure that unauthorized parties will not obtain access. We also cannot control how approved users store or transfer the information you give to us, so you should not post sensitive information to GameGleam.

We generally store information about you for as long as we need the information for the purposes for which we collect and use it, and we are not legally required to continue to keep it. For example, we will store order information for tax and accounting purposes. This includes your name, email address and billing and shipping addresses.

We will also store comments or reviews if you choose to leave them

6. HOW WE CAN SHARE THE INFORMATION

In certain situations, we may be required to disclose personal data in response to lawful requests by competent authorities, including meeting national security, public interests or law enforcement requirements. Our policies regarding exchange of information with competent authorities are reflected in Our Transparency Policy.

We may disclose your Personal Information where required by law (e.g., to comply with a subpoena, warrant, court order, or legal process served on GameGleam, and when we believe that disclosure is necessary to protect our rights, avoid litigation, protect your safety or the safety of others, investigate fraud, and/or respond to a government request.

We share Personal Information with certain companies that perform services on our behalf on a need-to-know basis. We require any company with which we may share Personal Information to protect that data in a manner consistent with this policy and to limit the use of such Personal Information to the performance of services for GameGleam

You agree that we may share and transfer your information which no longer identifies you to the third party (pseudonymisation) who is a contracting party with us, usually our service providers or advertising partners.

We may transfer personal data to entities outside of the EEA including in the United States, which countries may not have data protection laws as strict as those in the EEA. Where we transfer your information outside the EEA we will either undertake an assessment of the level of protection in light of the circumstances surrounding the transfer or:

- Only transfer it to a non-EEA country with privacy laws that give the same protection as the EEA; or

- Ensure we have an agreement in place with the recipient under which they are under a duty to protect your data to the same standards as those in place in the EEA; or

- We will make sure that any transfers are not repetitive and only limited to the minimum amount of information possible. In certain circumstances we may need to seek your consent unless there is an overriding legal need to transfer the information; and

- In all cases where your information is transferred outside the EEA, you have a right to contact us for information on the measures we have put in place.

7. HOW LONG WE RETAIN YOUR DATA

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website, we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time. Website administrators can also see and edit that information.

We will retain your information for as long as your account is active, your information is needed to provide you services, or as required to fulfill our legal obligations.

By contacting us at complaints@gamegleam.com you can at any time obtain the confirmation whether or not the personal data concerning you is being processed.

We may retain records where necessary to fulfil our regulatory or statutory duties.

8. WHAT ARE YOUR RIGHTS TO YOUR DATA

All Your Personal Information we collect will always belong to you. However, we are a collector and a processor of Your Personal Information. That implies on us obligations to respect your rights to Personal Information and facilitate the exercise of your rights thereto. In order to use any of your rights at any time please contact us and we will facilitate the exercise of your rights free of charge. We will inform you on the actions taken by us under your request as soon as practically possible, but in any case not later than in 30 (thirty) calendar days.

In accordance with effective regulations you have a significant number of rights related to your Personal Information, such as e.g.:

Right to access. You may obtain from us the confirmation as to whether or not personal data concerning you is being processed and get an access to such personal data. You are entitled to view, amend, or delete the personal information that we hold. Email your request to our data protection officer at complaints@gamegleam.com and we will work with you to remove any of your personal data we may have.

Right to rectify your inaccurate Personal Information and to have incomplete personal data completed, including by means of providing a supplementary statement

Right to erase your Personal Information. Please note that a request to erase your Personal Information will also terminate your account on the Site. We will automatically and without undue delay erase your Personal Information when it is no longer necessary in relation to the purposes for which it was collected or otherwise processed;

Right to restrict processing of your Personal Information;

Right to data portability. You may obtain from us the personal data concerning you and which you have provided to us and transmit it to another Personal Information Controller;

Right to object to processing of Your Personal Information,

Right to withdraw your consent to the usage of your Personal Information at any time

Right to lodge a complaint. We take privacy concerns seriously. If you believe that we have not complied with this Privacy Policy with respect to your Personal Information, you may contact our respective Data Protection Office. We will investigate your complaint promptly and will reply you within 30 (thirty) calendar days. If you do not receive acknowledgment of your complaint or your complaint is not satisfactorily addressed, you have the right to lodge a complaint with the respective supervisory authority:

Office of the Privacy Commissioner for Personal Data

https://www.pcpd.org.hk/english/complaints/how_complaint/complaint/complaint.html or (for EU) Information Commissioner’s Office https://ico.org.uk/make-a-complaint/ .

9. COOKIES POLICY

www.gamegleam.com may set and access cookies on your computer. Cookies are used to provide our system with the basic information to provide the services you are requesting. Cookies can be cleared at any time from your internet browser settings.

If you leave a comment on our site you may opt-in to save your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

10. EMBEDDED CONTENT FROM OTHER WEBSITES

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

11. GOOGLE ANALYTICS

When someone visits www.gamegleam.com we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to track things such as the number of visitors to the various parts of the site and interactions with the site. This information is processed in a way which does not identify anyone. We do not make and do not allow Google to make, any attempt to find out the identities of visitors to our website.

12. WEBSITE COMMENTS

When someone visits www.gamegleam.com there may be an ability to submit comments on particular articles or pages. When comments are submitted, you are entitled to use aliases or information that completely hides your identity. When a comment is submitted, the relevant details (name, email, and website) that you provide are stored. These details are stored so that we can display your comment back to you, and to anyone viewing the comment sections on the site. We do not verify the information entered nor do we require verification.

13. MEDIA

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

14. CHILDREN

We do not intend to solicit or collect Personal Information from anyone under the age of 13 or under the legal age of your country, if it is higher. If you are under 13 or are not of a legal age of your country, do not enter any personal information on our site.

Notwithstanding the provisions of child age restriction of this agreement, when using this Service, we encourage parents and guardians to spend time with their children, especially if the child is 12 and under (“Child” or “Children”). We will never request personally identifiable information from a Child in any of our public postings areas. We will not require a Child to disclose more personally identifiable information than is reasonably necessary to participate in any online activity. WE ASK PARENTS TO HELP US PROTECT THEIR CHILDREN’S PRIVACY BY INSTRUCTING THEM NEVER TO PROVIDE PERSONALLY IDENTIFIABLE INFORMATION ON THIS SERVICE OR ANY OTHER SITE WITHOUT FIRST GETTING PARENTAL/GUARDIAN PERMISSION.

15. CHANGES TO OUR PRIVACY POLICY

We may make changes to our Privacy Policy in the future; however, the most current version of the policy will govern our processing of your personal data and will always be available to you.

If we make a change to this policy that, in our sole discretion, is material, we will notify you by an update or email, where possible. By continuing to access or use our services, you agree to be bound to the terms of our Privacy Policy.

16. CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at complaints@gamegleam.com or by mail using the details provided below:

INFINITOUS GROUP, at Stockholm, Sweden